Privacy policy for the Ecommpay employer branding and recruitment

Last updated: 8th December 2025

INTRODUCTION

This Privacy Policy describes policies and practices of Ecommpay Limited (hereinafter– “Ecommpay”) regarding collection and processing of job applicants’ (hereinafter – “You”) personal data, as well as sets forth Your rights regarding processing of Your personal data.

INFORMATION ECOMMPAY MAY COLLECT FROM YOU

Ecommpay collects and processes the following personal data about You:

• Information contained in CV and application letter, submitted by You, for instance, name, surname, date of birth, place of residence, telephone number, e-mail address, education, previous places of employment, as well as other information specified in Your CV or application letter;
• Information required for ensuring security in Ecommpay’s office, for instance, information entered in the visitors’ registration log regarding the time of your stay in Ecommpay’s office, as well as information recorded by the CCTV cameras;
• Information provided by You during the interview and skill tests;
• Information necessary to verify whether You are included in the sanctions lists of the United Nations, the European Union, the United Kingdom or the Office of Foreign Assets Control (OFAC) of the United States of America, only in the event that Ecommpay wishes to express a job offer to You.

HOW ECOMMPAY USES YOUR PERSONAL DATA

Ecommpay uses Your personal data to evaluate Your suitability for the vacancy You have applied for. In respect to this purpose Ecommpay relies on Ecommpay’s legitimate interests of ensuring the appropriate human resource management processes.

Ecommpay may process your personal data for the purpose of testing Your professional skills and other competencies as well as Your personal qualities as part of the assessment of Your suitability for a particular vacancy, including the transfer of Your personal data to a service provider outside the European Economic Area (hereinafter – the “EEA”) or the UK, which provides the said candidate evaluation service to Ecommpay, while ensuring an adequate level of protection of your personal data. In this regard, Ecommpay relies on Your consent as the valid ground for the processing of Your personal data.

Ecommpay may process Your personal data to evaluate Your suitability for other vacancy existing at the time of Your application or at any time during one year from the moment you have applied for the current vacancy. In this regard, Ecommpay relies on Your consent as the valid ground for the processing of Your personal data, and You have the right to withdraw Your consent at any time.

Ecommpay processes Your personal data in order to establish whether You occupy a position in an executive body of any other company and to make a decision on the authorisation or restriction of combining the roles. In this regard, Ecommpay relies on Your consent as the valid ground for the processing of Your personal data, and You have the right to withdraw Your consent at any time.

In addition, Ecommpay relies on its legitimate interests to ensure security in Ecommpay’s office as the valid ground for the processing of Your personal data. In order to meet this objective, video surveillance is conducted in Ecommpay’s office.

In addition to the above-mentioned, in certain cases Ecommpay may process Your personal data in order to comply with the obligations set forth in the applicable laws and regulations. For instance, based on a legal obligation under the Financial Conduct Authority's regulation in the field of national sanctions, Ecommpay processes Your personal data before making a job offer to You, to verify whether You are included in the sanctions lists of the United Nations, the European Union, the United Kingdom or the Office of Foreign Assets Control (OFAC) of the United States of America for the purpose of ascertaining financial or entry restrictions, i.e., Your name, surname and date of birth, but in certain cases, if necessary and per request, any other personal data that would allow identification of You, such as Your country of birth, citizenship, country of residence, Your photo or passport details.

HOW LONG ECOMMPAY WILL KEEP YOUR PERSONAL DATA

Should Your application for the announced vacancy result in hiring You, Ecommpay will store Your personal data, submitted by You during the application process, throughout the entire period of the employment relationship and 5 (five) years after termination of the employment relationship, or longer, if it is permitted by the applicable law.

Should Your application for the announced vacancy not result in hiring You, Ecommpay will store Your personal data, submitted by You during the application process, 1 (one) year after receipt of Your application in order to consider Your suitability for employment in other potential future vacancies.

Ecommpay stores the data recorded by the CCTV cameras 3 (three) months from the moment of registration.

HOW ECOMMPAY DISCLOSES YOUR PERSONAL DATA

Ecommpay may transfer Your personal data to Ecommpay group companies located outside the EEA or the UK. Where such transfers of personal data take place, Ecommpay and Ecommpay group companies located outside the EEA or the UK have concluded the Standard Contractual Clauses, the International Data Transfer Agreement or International Data Transfer Addendum, thus guaranteeing and ensuring the adequate level of protection of Your personal data. In certain circumstances, Ecommpay may disclose Your personal data to regulatory authorities or law enforcement bodies in order to comply with Ecommpay’s legal obligations, as well as to protect Ecommpay’s rights and interests.

Ecommpay may also disclose Your personal data to third parties in relation to a complete or partial transfer, merger, acquisition or sale of assets of Ecommpay or its affiliates.

YOUR RIGHTS

You have certain rights in respect to the way Ecommpay treats Your personal data:

• You are entitled to receive a confirmation regarding what personal data Ecommpay processes about You, or, if You wish, to gain access to Your personal data;
• You are entitled to rectify Your personal data that is available to Ecommpay (for instance, in case of changes in telephone number, e-mail address or surname);
• You may also request Ecommpay to erase Your personal data available to Ecommpay or cease the further processing of Your personal data. However, please note that this right is not absolute and may be subject to certain exemptions. In such an event, we You will be informed accordingly;
• You may also request to not process Your personal data for purposes related to assessment of Your suitability for potential future vacancies;
• You may also request to receive Your personal data collected by Ecommpay or transmit it to another data controller. Ecommpay will comply with Your request, provided that the personal data processing previously carried out by Ecommpay was based on Your consent, and where it is technically feasible;
• You have the right to lodge a complaint to the Information Commissioners’ Office if You have grounds to believe that Ecommpay has not complied with the requirements of the UK General Data Protection Regulation with regard to Your personal data. However, before lodging a complaint to Information Commissioners’ Office, Ecommpay invites You to contact Ecommpay’s data protection officer in order to find a common solution.

SECURITY

All information, which is provided by You to Ecommpay and obtained by Ecommpay about You, is stored on secure servers, and Ecommpay applies appropriate organisational, technical and administrative measures to protect Your personal data. Once Your personal data is received by Ecommpay, Ecommpay uses strict procedures and security features to prevent any unauthorised access to Your data. However, please note that no transmission of information via the internet is completely secure and no storage system is guaranteed to be entirely secure. If You have any reason to believe that a third party has gained unauthorized access to the personal data provided by You to Ecommpay, You shall notify Ecommpay thereof in writing without delay.

CHANGES TO THE PRIVACY POLICY

Ecommpay may change or update this Privacy Policy. Any changes Ecommpay may make to this Privacy Policy in the future will be posted on Ecommpay’s website and any such changes will be effective starting from the date when the revised Privacy Policy is published.

DATA PROTECTION OFFICER

Ecommpay has appointed a data protection officer, whom You may contact, should You have any questions or concerns regarding Ecommpay’s personal data processing practices, including provision of appropriate guarantees for the protection of Your personal data. Ecommpay’s data protection officer’s contact information is as follows: dpo@ecommpay.com.